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According to counsel for the respondent [46] Account must be taken of all of the evidence and the contradictions in the testimony of both witnesses. [47] From 1986 to 1991, the appellant worked for the payer without pay. [48] It is very odd for a business to answer the telephone only in the afternoon. [49] The son has run his own errands since taking over. [50] Gérard Gosselin hired the appellant at a time when the payer’s business was on the decline. [51] He was mistaken at first about when the two contracts in question were lost, subsequently changing his mind in that regard. [52] From 1992 to 1996, Gérard Gosselin’s other spouse did only a little work for the payer. [53] The contract (Exhibit I-1) indicates that the appellant was being hired as of May 30, 1996, but she states in her claim for unemployment insurance benefits that she started working on May 13, 1996. [54] Her credibility is thus called into question. [55] The Minister considered all of the facts in making his determination. [56] Aside from the non-arm’s length relationship, there was nothing to justify hiring the appellant. [57] The appellant’s wages were not justified, since she worked without pay both before and after the period at issue; there was little or no control exercised over her work. ...

Moreover, as contended by counsel for the Respondent even if the loss can be considered (because of the continued existence of the corporation notwithstanding no operations) to have occurred in 1994 the loss would be nil since there was no proof to establish the amount of the loss. ...

Second, in what way is being a co-owner a factor to be considered in determining the existence of employment when the employment is genuine? ...

Pauzé considered the reimbursement of his expenses to be a form of pay is a very revealing indication that he may have been mistaken as to the tax treatment of the money paid to him by Référium. [9] Furthermore, I have no doubt that Référium really intended to pay its sole shareholder a dividend. ...

According to the appellant's testimony at page 36 of the transcript, those were the only expenses that had to be shared by the partners. [13]     As the appellant explained, the partners could each personally, depending on how motivated they were, incur the expenses they considered useful to earn "royalties" paid by Titrex. ...

Millar testified that his personal car was a 1977 Lincoln, which, because of its age, he considered to be unreliable for use on business trips that took him away from the City of Edmonton. ...

Subsection 3(2) lists what is considered "excepted employment" for the purposes of the Act. ...

Other factors were considered to come to the negotiated result, including the doctor built into the hourly rate compensation for the use of his premises, his equipment, his receptionist and allocation for the reception area in the offices that he provided. ...

He submitted that he considered this to be a basis for reassessment by the Minister of National Revenue ("Minister") because paragraph 6(e) of the Reply to the Notice of Appeal, setting forth "assumptions of fact" made by the Minister stated: As of May 1, 1991, the fair market value of the Northeast Quarter was for the most part dependant upon the value of the deposits of limestone contained under the surface of the property. ...

Hausmann was a social security pension within the meaning of the treaty appears not to have been considered. [17] I start with the Income Tax Act. ...